https://www.taxtmi.com/caselaws?id=352586 Transfer pricing adjustments under Chapter X apply only to international transactions with associated enterprises. Ordinary domestic transactions cannot be included in the adjustment base unless they qualify as specified domestic transactions. Where segmental accounts are unavailable, any proportionate adjustment should relate only to the international transaction component, reflecting the presumption that dealings with non-associated enterprises are at arm's length. Reassessment of a royalty-income reversal should be considered alongside the transfer pricing issue when both are remitted for fresh examination, following the procedure applicable to such reassessment proceedings. en-us Thu, 16 Nov 2017 00:00:00 +0530 Sat, 16 Dec 2017 15:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=352586 Transfer pricing adjustments under Chapter X apply only to international transactions with associated enterprises. Ordinary domestic transactions cannot be included in the adjustment base unless they qualify as specified domestic transactions. Where segmental accounts are unavailable, any proportionate adjustment should relate only to the international transaction component, reflecting the presumption that dealings with non-associated enterprises are at arm's length. Reassessment of a royalty-income reversal should be considered alongside the transfer pricing issue when both are remitted for fresh examination, following the procedure applicable to such reassessment proceedings. Case-Laws Income Tax Thu, 16 Nov 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=352586